Law School Audio Flashcards

For our fifth and final episode in the SALT series, we are going to discuss general principles of individual multi-state taxation, the use of the OSTC (other-state tax credit), and modern issues arising from the prevalence of remote work. I hope you enjoyed this series. If there are any other subjects you would like me to cover, please let me know in the comments or by DM.

In Episode 4 of 5 in our SALT series, we will examine consumption taxes, such as sales and use taxes and related amalgamations thereof in this modern digital economy.

This is Episode 3 of 5 of our accelerated series on SALT (State and Local Taxation). Today we are tackling one of the most mechanically complex but conceptually fascinating areas of State and Local Tax: Apportionment and the Unitary Business Principle. We must answer the question: once a state has the constitutional authority to tax a multistate corporation, exactly how much of that corporation&#3...

For Episode 2 of 5 of our accelerated series on SALT, we will examine P.L. 86-272, codified at 15 U.S.C. §381, a rare instance of Congressional intervention of states' sovereignty to tax activity within its borders.

For our first episode in the five-part series on State and Local Tax, or SALT, we will examine the Constitutional limitations on states' imposition of tax on both residents and nonresidents and the history of jurisprudence starting in the mid-20th century until today.

For our eighth and final episode of our series on Corporate Tax, we will examine the tax-free reorganization provisions under §368(a)(1) and the related basis provisions. Please let me know if there are any other subjects you'd like me to cover. -Guy

In the seventh episode of our Corporate Tax series, we will review the principles contained under §§ 1060, 338, and 336(e), each relating to the tax treatment of a taxable asset sale.

Episode 6 in our Corporate Tax series covers the entity level liquidation implications codified under §336 and the related provisions under §§ 332 and 337 pertaining to parent-sub scenarios. Finally, we will briefly touch on the residual allocation method prescribed under §1060 for business acquisitions structured as asset deals for tax purposes.

Episode 5 is a long one, covering stock dividends under §305 and corporate liquidations under §331, along with the basis rules for each provision under §307(a) and §334(a) respectively, plus some ancillary or related provisions.

In Episode 4 of our Corporate Tax series, we will review the "not essentially equivalent" to a dividend standard, the corporate contraction doctrine codified under §302(e), and §312(n)(7) adjustments to E&P resulting from §302 treatment.

In Episode 3, we will explain redemptions (as defined under §317(b)) under IRC §302 and also introduce attribution under §318.

For Episode 2 of our Corporate Tax series, we will review the treatment of corporate distributions under §§ 301, 312, and 316.

In this inaugural episode of the Corporate Tax series, we will discuss the concept of the corporate double tax in US taxation, formation of a C-corporation, and calculation of the shareholder's stock basis and the corporation's inside property basis.

In our final episode, we will do a high-level review of our international tax survey course, along with recommended approaches to different types of fact patterns.

In this episode, we will review the topic of tax treaties in international taxation.

In this episode, we will examine foreign tax credits a post-OBBBA world.

In this episode, we will examine §250 Foreign-Derived Deduction Eligible Income.

In this episode, we will review GILTI and NCTI in 2026.

For Episode 5, we will be examining the Subpart F regime under §§ 951-954.

For this episode, we will look at expatriation under §§877 and 877A, and the Branch Profits Tax under § 884.

For Episode 3, we will be examining the sourcing rules under §§ 861-865.

For our 2nd episode on international taxation, we will look at the dual income track under §§ 871, 881, and 882.

Episode 1, Jurisdiction and Residency, surveys the law around determining whether you are a US resident subject to worldwide taxation, or a nonresident alien (NRA) taxed only on US source income.

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